North Korean animation outsourcing for Amazon, HBO Max series
31–40 of 305 posts
Re: North Korean animation outsourcing for Amazon, HBO Max series
#32Re: North Korean animation outsourcing for Amazon, HBO Max series
#33Re: North Korean animation outsourcing for Amazon, HBO Max series
#34Re: North Korean animation outsourcing for Amazon, HBO Max series
#35> There is no evidence to suggest that the companies identified in the images had any knowledge that a part of their project had been subcontracted to North Korean animators. In fact, as the editing comments on all the files, including those related to US-based animations, were written in Chinese, it is likely that the contracting arrangement was several steps downstream from the major producers.
Re: North Korean animation outsourcing for Amazon, HBO Max series
#36Generally, how far downstream does the US State Department expect companies to vet vendors for sanctions violation? Due diligence this many layers deep is expensive, especially if hostile (investigative work to proactively discover dishonest sourcing reports.) I would think it would vary by industry--e.g. animation is obviously less stringent than medical devices so would have fewer reporting and certification struct…
There isn't ever a sense of "I'm doing enough and therefore the sanctions violations happening are no longer my fault". It's somewhat up to you to determine your risk and tailor your compliance program to address them and to adjust if you're ever wrong.
How guilty you are is a function of how good a job the state department thinks you're doing trying to avoid sanctions violations.
Re: North Korean animation outsourcing for Amazon, HBO Max series
#37Re: North Korean animation outsourcing for Amazon, HBO Max series
#38Seems like a difficult problem to solve. It shows the importance of paying close attention. NK has shown to be quite good at bypassing sanctions but it seems that the link is almost always through China. It would seem that the best way to go about this would be through stricter negotiations with them, since they are already acting as a significant intermediary. Either they know about this or the great firewall is not…